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2 About the Canadian Institute of Actuaries The Canadian Institute of Actuaries is the national organization of the actuarial profession. Actuaries employ their specialized knowledge of the mathematics of finance, statistics and risk theory on problems faced by pension plans, government regulators, insurance companies (both Life and Property/Casualty), social programs and individuals. The CIA establishes the Rules of Professional Conduct and monitoring and discipline processes for qualified actuaries, all of whom must adhere to the profession s standards of practice. Under its Guiding Principle 1, the CIA holds the duty of the profession to the public above the needs of the profession and its members. The CIA also assists the Actuarial Standards Board in developing standards of practice applicable to actuaries working in Canada.

3 C A N A D A S A C T U A R I E S A D V O C AT E C H A N G E The Canadian Pension System Needs To Be Retooled For some time, it has been apparent that the Canadian pension system is facing dire circumstances. The economic crisis that we witnessed in 2008 has impacted the retirement expectations of many Canadians. Large funding deficits have emerged in a number of plans, and pensioners and workers from companies facing bankruptcy now run the risk of having their benefits reduced. Individuals have watched as the accumulated savings in their RRSPs and Defined Contribution plans have melted away. With so many issues facing our current pension system, there have been several calls to investigate alternate forms of retirement savings. Unfortunately, over the course of many years, pension plan issues have become extremely complex. In addition to the long-lasting asymmetric rules regarding the treatment of surpluses and deficits, the various bodies involved in the regulation of pension plans have acted independently and have focused on their own separate objectives, resulting in a very complex operational playing field. Recent changes to pension accounting standards have created volatility in the plan sponsor s balance sheet and they have been reluctant to introduce new pension plans, and many have terminated existing plans. For plans that remain, plan sponsors have been inclined to minimize their contributions and reduce the volatility in their balance sheets. In 2007, the Canadian Institute of Actuaries issued A Prescription for Canada s Ailing Pension System. Since that time, a number of environmental factors have prompted the Institute to revisit this issue and provide an update on its current position. This document represents the Institute s recommendations to retool Canada s Pension System. Canadians Are Not Saving Enough For Retirement A study conducted in 2007 by the University of Waterloo, and sponsored by the Canadian Institute of Actuaries, discovered that two-thirds of Canadians who plan to retire in 2030 may not be saving at the levels required to meet household expenses in retirement. As the coverage of employer-sponsored pension plans continues to shrink, the potential for significant retirement income gaps has increased for a large number of Canadians. This matter is of paramount importance and serious corrective measures must be developed now to avoid a critical situation. Within this document, we have introduced a series of recommendations that would greatly enhance the Canadian Pension System, and promote increased pension coverage and provide additional retirement security for Canadian workers and retirees. 1 C A N A D I A N I N S T I T U T E O F A C T U A R I E S

4 R E T O O L I N G C A N A D A S A I L I N G P E N S I O N S Y S T E M N O W, F O R T H E F U T U R E Canadians Need Wider Coverage Only 17% of private sector workers in Canada are covered by a Defined Benefit pension plan, which is down from 26% in Although the percentage of private sector workers covered by Defined Contribution plans has increased from 4% to 7% over the same period, we are still left with the fact that fewer than one in four workers in the private sector belongs to a pension plan of some sort. 1 This leaves a significant number of workers on their own in terms of securing an adequate retirement income, relying on personal savings and Registered Retirement Savings Plans (both individual and group). Recent proposals have been made for universal plans, which would make a government-sponsored pension plan available to any worker who wishes to participate. Other organizations propose expanding the Canada/Québec Pension Plan. The evaluation of these proposals should consider the impact on the other pillars of the Canadian Pension System. Our system is envied by most countries, and it is built on three separate pillars: government plans (OAS/GIS/CPP/QPP); private employmentrelated plans; and personal savings. These three pillars create an equilibrium, whereby there is incentive for employers and individuals to take responsibility for retirement planning, with government programs providing a partial safety net. We believe that such an equilibrium must be maintained. One of the impediments to wider coverage by employer-sponsored plans is a lack of consistency in pension plan legislation across the provinces. This discourages employers whose workforce is governed by multiple jurisdictions from establishing a pension plan. Another significant impediment is the short-term volatility in the results reported in the financial statements of employers who sponsor Defined Benefit plans due to new accounting rules. This has led financial analysts to consider Defined Benefit plans as a negative factor in the valuation of organizations. In response, we recommend the following: 1. Pensions should be included on the national agenda, with the goal of creating an environment conducive to maintaining and strengthening pension plans including achieving consistency of pension legislation across jurisdictions. We strongly support the convening of a national summit of the appropriate ministers to discuss pension issues. The actuarial profession is willing to collaborate with regulators and industry to identify measures to reduce the administrative burden faced by plan sponsors and administrators in the ongoing management of pension plans. 2. Regulators should develop a principles-based approach to the supervision and monitoring of pension plans. It should be designed to remove significant obstacles to the maintenance and improvement of Defined Benefit plans and other plan designs. For example, the development of hybrid plans is hindered by various specific rules, such as current cost-sharing rules. 1 Statistics in this section are from Statistics Canada Catalogue no X C A N A D I A N I N S T I T U T E O F A C T U A R I E S 2

5 C A N A D A S A C T U A R I E S A D V O C AT E C H A N G E Canadians Need More Flexibility When They Reach Retirement Age When the commonly accepted retirement age of 65 was developed several years ago, life expectancy was markedly shorter than it is today. Retirement income was expected to be paid for a limited period of time. But today s retirees expect to live longer with a much more active lifestyle than previous generations. Many Canadians can be, and want to be, productive beyond age 65. As well, employers can benefit greatly from the experience and knowledge that older workers can contribute. Retirement programs that encourage retirement at a fixed age could have a detrimental effect on both parties. Older workers should be encouraged to continue gainful employment if they desire to do so, and early retirement benefits should be examined to see if they are consistent with this concept. On this issue, we recommend the following: 3. Disincentives to working past a fixed age in our current retirement system should be examined and rectified. We support facilitating innovative employment models that allow Canadians to work part-time while collecting partial retirement benefits. Canadians Need More Education On Retirement Issues Retirement requires prudent planning. Many Canadians may not be aware of how much they need to save in order to retire independently. Better financial education at an early age needs to become a priority. We are encouraged by the report of the Alberta/BC Joint Expert Panel on Pension Standards, which calls for increased financial literacy at the high school level. In terms of retirement, Canadians should be aware of the following: The risk factors associated with retirement, for example, longevity, inflation, investment rates of return, and the value of starting to save early; The costs associated with saving for retirement, such as management fees, which can vary between different savings vehicles; Retirement income adequacy. How much income will be necessary at various stages of the retirement period, and how does that differ from a regular working income; Working years versus retirement years. Expectations around the length of both need to be realistic; and Risk management. Retirement savings vehicles such as RRSPs can carry certain risks, depending on the nature of the underlying investments. Canadians need to understand their risk tolerance and manage their finances appropriately. In light of this, we recommend the following: 4. More information should be made available to Canadians, so they can clearly understand the risk factors associated with retirement, and manage those risks in a timely and effective manner. Plan sponsors both public and private should be encouraged to present information to their plan members that effectively addresses this need. Access to independent financial advice would also be beneficial. We also support the development of tools that can be easily used by Canadians to assimilate the various sources of retirement income to understand what they can expect to receive. 3 C A N A D I A N I N S T I T U T E O F A C T U A R I E S

6 R E T O O L I N G C A N A D A S A I L I N G P E N S I O N S Y S T E M N O W, F O R T H E F U T U R E Canadians Need Defined Benefit Plans Let s Save Them And Bring Them Back Although Defined Benefit pension plans are not the only means by which retirement income can be provided, we believe that they are particularly effective. Their demise is not in the best interest of Canadians both employees and employers. For Defined Benefit plan members, retirement income is more predictable, and this facilitates better retirement planning. As well, Defined Benefit plans help to insulate members from the risks associated with longevity, low interest rates, and market volatility. Because pension plan assets can be pooled in large amounts and a longer investment horizon can be considered, a member has a better chance to benefit from higher investment returns over time. For plan sponsors, Defined Benefit plans act as an effective workforce management tool that helps to attract and retain employees. As well, these plans provide the same retirement income more efficiently and at less cost than other retirement vehicles, and they do not need to be an excessive financial burden on employers. We acknowledge, however, that some changes are necessary and we recommend the following: 5. Introduce legislation that allows employers to set up 100% employer-funded Pension Security Trusts that would be separate from, but complementary to, the regular Defined Benefit pension funds. The contributions arising from going concern valuations would go into the regular pension fund, while additional contributions (including those required to fund solvency deficiencies) would be made to the Pension Security Trusts. Money in the Pension Security Trusts should be released back to the employer if a subsequent solvency valuation showed that it was no longer needed for the funding of the Defined Benefit plan. Amounts contributed into the Pension Security Trusts would be tax deductible, while amounts released back to the sponsor would be taxable. Defined Benefit plans can provide benefit security for workers and retirees provided the pension benefits themselves are adequately funded. As we have seen in the past though, underfunded pension plans can lead to benefit reductions in the event of a company s bankruptcy. This benefit reduction risk greatly reduces the security that Defined Benefit plans were designed to deliver. One element that can lead to inadequate funding is an adverse fluctuation in the value of the pension plan s assets. Prudent risk management would normally compel pension plan sponsors to develop a contingency margin so that these adverse fluctuations could be mitigated. However, restrictive tax rules and lack of clarity over the ownership of plan surpluses have created obstacles and disincentives for plan sponsors. In this regard, we recommend the following: 6. Assuming that the Pension Security Trust concept is adopted, the introduction of legislation would require that each Defined Benefit plan sponsor establish a Target Solvency Margin related to the risks in the plan s assets and liabilities and be funded by a Pension Security Trust, a Letter of Credit or the regular pension fund. Contribution holidays would not be permitted if the plan s surplus was less than the Target Solvency Margin. For example, a particular plan might have a Target Solvency Margin of 5%, so that the plan sponsor would have to make current service contributions, as long as the plan assets were less than 105% of the solvency liabilities. 7. The establishment of a task force with representation from the Canadian Institute of Actuaries and pension regulators to develop guidance on the required levels of Target Solvency Margins. The Target Solvency Margin for a particular plan should take into account the risks faced by the plan, which may include reflecting its member demographics, financial strength of the sponsor, investment policy and the extent of its asset-liability mismatch. C A N A D I A N I N S T I T U T E O F A C T U A R I E S 4

7 C A N A D A S A C T U A R I E S A D V O C AT E C H A N G E 8. Changes to the tax rules, which would allow Defined Benefit plan sponsors to make contributions to develop surpluses that are the greater of two times the Target Solvency Margin, or 25% of the going concern liability. In our view, Pension Security Trusts, Target Solvency Margins and the higher level of plan surpluses are designed to work together and as such, any enabling legislation needs to reflect this. Had the above changes been in place, the funding problems created by the recent market turmoil would have been less significant and might not have required the implementation of special funding relief measures. Nevertheless, the recent economic crisis has demonstrated that benefit security can be threatened by external events such as a significant downturn in equity markets. We believe that pension benefits should be granted protection in the event of a company s bankruptcy. On this subject, we recommend the following: 9. Legislation to protect underfunded pension benefits, possibly by providing them with treatment similar to that of unpaid salaries in bankruptcy and restructuring proceedings. We acknowledge that gradual implementation of such legislation would be required in order to fully assess the various implications of its adoption on our economy. 10.On a going-forward basis, legislation should be modified to better handle the determination of benefits when the unfunded plan of a bankrupt employer is wound up. Such legislation could contemplate a hierarchy in the entitlement of benefits, whereby plan assets are first allocated to a basic promise and subsequently to ancillary benefits. In general, we propose a more comprehensive risk management perspective when dealing with pension plans. Stakeholders need to understand the inherent risks within the pension plan itself, as well as the wider potential impact on the sponsoring employer. These risks need to be effectively mitigated, where possible. The risk to the plan member of reduced or foregone benefits needs to be kept at a reasonably low level to preserve adequate benefit security. We are committed to encouraging further research to develop methods that enhance risk management practices in pension plans. Conclusion We call on all parties to take immediate action on our retooling strategy, so that Canadians can benefit from a pension system that favours strong and secure pension promises, provides flexibility in plan design, and includes the necessary incentives for action. This will lead to a safer and more certain future for today s workers and retirees. 5 C A N A D I A N I N S T I T U T E O F A C T U A R I E S

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